CFSS LSJ_V2 interim APPROVED_Redacted.pdf

LIMITED SOURCES JUSTIFICATION

SECTION 1: IDENTIFICATION OF THE AGENCY AND THE CONTRACTING ACTIVITY

Department of State Contracting Activity Office of Acquisitions Management

Requiring Activity Bureau of the Comptroller and Global Financial Services (CGFS), Chief Information Officer Directorate (CIO)

SECTION 2: NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

Approval is requested to limit the number of sources for awarding an order under a Federal Supply Schedule contract for the services described in Section 3 on behalf of the Requiring Activity, currently provided by SOS International, LLC (SOSi) via task order SAQMMA14F2094. The existing task order is issued against General Services Administration (GSA) Multiple Award Schedule (MAS) contract GS35F4951H.

This planned labor hour interim award is requested to continue critical services while the Department of State (DoS or Department) responds to a protest received regarding a relevant recompeted effort.

SECTION 3: DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED TO MEET THE AGENCY’S

NEEDS

Task order SAQMMA14F2094 provides payroll and associated financial system support, including the Global Foreign Affairs Compensation System (GFACS), for the Compensation and Financial System Services (CFSS) program. The CFSS program supports the systems that pay Foreign Service Officers, Civil Service employees, Foreign Service Annuitants, and Locally Employed Staff (LES) in approximately 170 countries. Pay rules are constantly changing, necessitating the pay systems to be updated to correctly pay employees. The task order also provides support services for the disbursing system that pays the US Government’s expenses overseas, including payroll, in multiple currencies. In addition, the task order provides services for financial management support systems implemented to provide oversight. CFSS has migrated to GFACS, a web-based application based on commercial software utilizing Oracle PeopleSoft. The ongoing task order is comprised of four overarching task areas including: A) CGFS/GFMS Program Management and Analysis; B) CGFS/GFMS Development, Maintenance, and Enhancement (DME); C) CGFS/C Operations Support; and D) GFACS American Payroll Time and Labor application development and implementation support.

This LSJ requests an interim award to permit sufficient time to respond to the protest (e.g., take corrective action or defend), draft requisite documents, traverse relevant processes, issue an award, and allow time for transition activities, if necessary.

DoS and other agencies would experience a severe impact if this interim award is not permitted. Without these services, DoS will not be able to pay personnel or overseas vendors correctly nor be able to effectively manage financial operations in accordance with Department policy and Federal regulations.

An interim award with a period of performance (POP) consisting of one, six-month base period, and one, six-month option period is requested. The estimated value for the entire period of performance is .

SECTION 4: AUTHORITY AND SUPPORTING RATIONALE

This acquisition is conducted under the authority of the Multiple-Award Schedule Program (41 U.S.C. 152(3) and 40 U.S.C. 501), as implemented in FAR 8.405.6 by the following:

FAR 8.405-6(a)(1)(i)(A) - An urgent and compelling need exists, and following the procedures would result in unacceptable delays.

DoS utilizes the Global Foreign Affairs Compensation System (GFACS) legacy payroll systems and Global Financial Management Systems (GFMS) for compensation and financial management activities. The current customer base for DoS compensation systems includes American DoS employees located worldwide, Locally Employed Staff (LES), domestic and overseas personal services contractors, and Foreign Service Annuitants and qualified beneficiaries. Additionally, DoS provides payroll cross servicing for several overseas employees from other agencies. GFACS is a PeopleSoft based application requiring specific technical and functional expertise. The chief unique qualification of the contractor is its ability to maintain the current level of support to GFACS to reduce the risk of degradation or cessation of services. CFSS is a multi-year, extremely complex program with high visibility within and beyond DoS. SOSi is the current contractor implementing the application and providing ongoing application support and development for the American Payroll functionality. Removing SOSi at this time without a replacement contractor would severely adversely impact DoS payroll functionality, causing significant disruption of payroll operations with a substantial associated cost increase. The chief unique qualification of the contractor is its ability to seamlessly maintain the current level of expert support to GFACS, thereby reducing the risk of degradation or cessation of services, which would adversely impact the ability to pay DoS employees worldwide.

Contract History On July 10, 2014, DoS awarded task order SAQMMA14F2094 against GSA MAS Schedule 70 contract GS35F4951H to STG, Inc (now SOS International, LLC – SOSi). The award provided for one base year and four option years. All options have been exercised. The POP originally ended on June 30, 2019, and was extended to December 31, 2019 pursuant to FAR clause 52.217-8, Option to Extend Services. The acquisition process for a follow-on CFSS contract was initiated. Due to delays encountered throughout the acquisition process, including evolving technical requirements and continuing personnel resource constraints, interim extension modifications were awarded to maintain continuity of services; the current POP end date is August 31, 2025.

A solicitation was previously issued in December 2020. Proposals were received and evaluated, discussions were conducted, and revised proposals were also evaluated. CGFS’s changing requirements after award of the interim extension (P00084 extended the POP from December 1, 2023 through May 31, 2024, with two, three-month option periods, ending on November 30, 2024) led to solicitation cancellation for the then-ongoing competitive process in May 2024. The Contracting Officer subsequently issued modification P00091 to further extend the POP for six months, December 1, 2024 through May 31, 2025, plus one, three-month option period through August 31, 2025.

During the extensions, CGFS’s requirements were finalized and market research was conducted. A Request for Quote (RFQ) for a Blanket Purchase Agreement (BPA) was issued to GSA Schedule 70 contract holders as an unrestricted competition on October 30, 2024. Quotes were received by November 29, 2024; the Technical Evaluation Team began evaluating quotes on January 13, 2025, with oral presentations occurring on February 18, 2025 through February 20, 2025. The Technical Evaluation Team submitted the Chairperson’s technical recommendation on April 2, 2025. The Contracting Officer subsequently completed the Source Selection Recommendation and Decision and routed the draft award for approval, including Senior Bureau Official (SBO) approval, which was received on July 8, 2025. BPA 19AQMM25A0812 was awarded on July 9, 2025 to notices to unsuccessful offerors were issued the following day. SOSi filed a protest with the Government Accountability Office (GAO) on July 21, 2025; the Contracting Officer issued a stop-work order on the same day.

Given that the POP for the current CFSS task order (SAQMMA14F2094) ends on August 31, 2025, an interim award for a total of 12 months (one, six-month base period, and one, six-month option period) is requested to ensure further continuity of service. During this period, the Contracting Officer, CGFS, and L/BA will work diligently to respond to the protest, resulting in an award and potentially transition activities.

SECTION 5: DETERMINATION BY THE ORDERING ACTIVITY CONTRACTING OFFICER THAT THE

CONTRACT ACTION REPRESENTS THE BEST VALUE CONSISTENT WITH FAR 8.404(D)

The Contracting Officer has determined the anticipated contract action will represent the best value based on the Contracting Officer’s plan to follow the procedures in FAR 8.405. Although approval is requested to contract with one source, the Contracting Officer will not award the planned contract action unless the Contracting Officer evaluates and determines that the resultant price is reasonable.

Moreover, GSA has deemed MAS contract pricing to be fair and reasonable. DoS will review the technical content of the price quote prior to award. The Contracting Officer will ensure that reasonable discounts from GSA MAS IT contract rates are provided where applicable/appropriate. Based on these factors, the Contracting Officer will have full information to determine price reasonableness for the extension period.

SECTION 6. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AMONG SCHEDULE

HOLDERS AND THE RESULTS OR A STATEMENT OF THE REASON MARKET RESEARCH WAS

NOT CONDUCTED